general npdes permit for residual order … npdes permit for residual order no. 2013-0002-dwq ......

GENERAL NPDES PERMIT FOR RESIDUAL ORDER NO. 2013-0002-DWQ AQUATIC PESTICIDE DISCHARGES FROM NPDES NO. CAG990005 ALGAE AND AQUATIC WEED CONTROL APPLICATIONS

ATTACHMENT E – NOTICE OF INTENT E-2

IV. RECEIVING WATER INFORMATION A. Algaecide and aquatic herbicides are used to treat (check all that apply):1. Canals, ditches, or other constructed conveyance facilities owned and controlled by Discharger.

Name of the conveyance system: ________________________________________________ 2. Canals, ditches, or other constructed conveyance facilities owned and controlled by an entity other

than the Discharger. Owner’s name:________________________________________________________________Name of the conveyance system: _________________________________________________

3. Directly to river, lake, creek, stream, bay, ocean, etc. Name of water body: ___________________________________________________________

B. Regional Water Quality Control Board(s) where treatment areas are located (REGION 1, 2, 3, 4, 5, 6, 7, 8, or 9): Region ______________________________________________

(List all regions where algaecide and aquatic herbicide application is proposed.)

V. ALGAECIDE AND AQUATIC HERBICIDE APPLICATION INFORMATION A. Target Organisms: ____ B. Algaecide and Aquatic Herbicide Used: List Name and Active ingredients

C. Period of Application: Start Date________________________ End Date_______________________

D. Types of Adjuvants Used:

VI. AQUATIC PESTICIDE APPLICATION PLAN

Has an Aquatic Pesticide Application Plan been prepared and is the applicator familiar with its contents? Yes No

If not, when will it be prepared? ____________________

VII. NOTIFICATION

Have potentially affected public and governmental agencies been notified? Yes No

VIII. FEE

Have you included payment of the filing fee (for first-time enrollees only) with this submittal? YES NO NA

San Francisco Bay RWQCB (2)

Widgeon Grass, Planktonic Algae, and Filamentous Algae

January "for the life of permit" December "for the life of permit"

Cygnet Plus (Active Ingriedients - Limonene, methylated vegetable oil, alkyl hydroxypoly oxyethylene)

X

X

X

Herbicides - Reward (diquat) Nautique (Copper Carbonate)Algaecides - Cutrine Plus (Copper as Elemental) GreenClean Liquid (Hydrogen Dioxide) PAK27 (Sodium CarbonatePeroxyhydrate) Hydrothol 191 (Mono N, N-dimethylalkylamine salt of endothall)

Alameda Lagoons

AQUATIC PESTICIDE APPLICATION PLAN (APAP)

Alameda Lagoons

Page 1 of 44

AQUATIC PESTICIDE APPLICATION PLAN

(APAP) Alameda Lagoons

Prepared By:

CLEAN LAKES, INC.

2150 Franklin Canyon Road

Martinez, California 94553

www.cleanlake.com

CITY OF ALAMEDA

Public Works Department

950 W. Mall Square, Room 110

Alameda, CA 92501

August 2013

Purpose: To meet the requirements and ensure compliance with Water Quality Order No. 2013-0002-DWQ, Statewide

General National Pollutant Discharge Elimination System Permit for Residual Aquatic Pesticide Discharges to Waters of the

United States from Algae and Aquatic Weed Control Applications, General Permit No. CAG990005, adopted by the

State Water Resource Control Board on March 5, 2013


Alameda Lagoons

Page 2 of 44


Alameda Lagoons

Page 3 of 44

Contents BACKGROUND INFORMATION ................................................................................... 4

DESCRIPTION OF THE TREATMENT AREA............................................................. 14

AQUATIC PESTICIDES AND ADJUVANTS EXPECTED TO BE USED AND

APPLICATION METHODS ............................................................................................ 15

MONITORING AND REPORTING PROGRAM ........................................................... 18

Monitoring Requirements ............................................................................................. 18

Receiving Water Monitoring ........................................................................................ 20

Reporting........................................................................................................................... 30

Annual Report ............................................................................................................... 30

24 Hour Report and Five Day Reporting ...................................................................... 31

DESCRIPTION OF PROCEDURES TO PREVENT SAMPLE CONTAMINATION .. 32

DESCRIPTION OF BEST MANAGEMENT PRACTICES (BMPs) TO BE

IMPLEMETED: ................................................................................................................ 33

EXAMINATION OF AQUATIC VEGETATION CONTROL ALTERNATIVES........ 37


Alameda Lagoons

Page 4 of 44

BACKGROUND INFORMATION

This Aquatic Pesticide Application Plan (APAP) is a comprehensive plan developed by

the discharger to comply with the provisions of Water Quality Order No. 2013-0002-

DWQ, Statewide General National Pollutant Discharge Elimination System Permit for

Residual Aquatic Pesticide Discharges to Waters of the United States from Algae and

Aquatic Weed Control Applications, General Permit No. CAG990005, adopted by the

State Water Resource Control Board on March 5, 2013.

This Aquatic Pesticide Application Plan (APAP) describes the project site, aquatic plant

and algae nuisances, aquatic pesticide products expected to be used, the monitoring

program, and Best Management Practices to be followed, as well as the other conditions

addressed in the General Permit, Section VIII C, Aquatic Pesticide Use Requirements,

Aquatic Pesticide Application Plan.

The use of aquatic pesticides within the Alameda Lagoons is necessary to manage the

lake and maintain the beneficial uses that include storm water retention, fishing,

swimming, boating, aesthetics, and a habitat and resting place for waterfowl and

migratory birds. The Aquatic Vegetation Control Program is an undertaking necessary to

control specific types of aquatic vegetation and algae that have become a nuisance to the

management of the water body and are impacting its health and beneficial uses. The need

for aquatic pesticide application events as part of this program vary from week to week

and from season to season due to such things as water temperature, sunlight, nutrient

levels, plant and algae growth and other factors. This APAP per the General Permit

requirements described below provides the outline to ensure that the Aquatic Vegetation

Control Program is successful.

PERMIT COVERAGE: The General Permit (No. CAG990005) addresses the discharge

of aquatic pesticides related to the application of 2,4-D, acrolein, copper, diquat,

endothall, fluridone, imazapyr, glyphosate, sodium carbonate peroxyhydrate, triclopyr

based algaecides and aquatic pesticides, and adjuvants containing ingredients represented


Alameda Lagoons

Page 5 of 44

by the surrogate nonylphenol. Aquatic pesticides that are applied to application areas

within waters of the United States in accordance with FIFRA label requirements and Use

Permit restrictions are not considered pollutants. However, residues associated with

aquatic pesticide application require coverage under the General Permit. These include

over-applied or misdirected pesticide products and pesticide residues. Residues are any

pesticide byproduct, or breakdown product, or pesticide product that is present after the

use of the pesticide to kill or control the target weed.

The General Permit does not cover agricultural storm water discharges or return flows

from irrigated agriculture because these discharges are not defined as “point sources” and

do not require coverage under an NPDES permit. The General Permit also does not cover

other indirect or non-point source discharges from applications of pesticides, including

discharges of pesticides to land that may be conveyed in storm water or irrigation runoff.

The General Permit does not cover the discharge of pollutants related to applications of

pesticides other than 2,4-D, acrolein, copper, diquat, endothall, fluridone, imazapyr,

glyphosate, sodium carbonate peroxyhydrate, triclopyr based algaecides and aquatic

pesticides, and adjuvants containing ingredients represented by the surrogate nonylphenol

based pesticides; however, the General Permit includes a re-opener statement specifying

that the permit may be reopened for the specific purpose of modifying the list of

pesticides whose associated discharge is authorized by this General Permit.

WATERS OF THE UNITED STATES: The General Permit regulates the discharge of

residues associated with the application of aquatic pesticides to waters of the United

States. “Waters of the United States” are defined by the General Permit as follows:

1. All waters which are currently used, were used in the past, or may be

susceptible to use in interstate or foreign commerce, including all waters which are

subject to the ebb and flow of the tide;

2. All interstate waters, including interstate “wetlands;”

3. All other waters such as intrastate lakes, rivers, streams (including intermittent

streams), mudflats, sand flats, “wetlands,” sloughs, prairie potholes, wet meadows, playa

lakes, or natural ponds the use, degradation, or destruction of which would affect or could

affect interstate or foreign commerce including any such waters:

a. Which are or could be used by interstate or foreign travelers for

recreational or other purposes;


Alameda Lagoons

Page 6 of 44

b. From which fish or shellfish are or could be taken and sold in interstate

or foreign commerce; or

c. Which are used or could be used for industrial purposes by industries in

interstate commerce.

4. All impoundments of waters otherwise defined as waters of the United States

under this definition;

5. Tributaries of waters identified in items 1 through 4 of this definition;

6. The territorial sea; and

7. "Wetlands" adjacent to waters (other than waters that are themselves wetlands)

identified in paragraphs (1) through (6) of this definition. Waste treatment systems,

including treatment ponds or lagoons designed to meet the requirements of CWA (other

than cooling ponds as defined in 40 C.F.R. section 423.11(m) which also meet the criteria

of this definition) are not waters of the United States. This exclusion applies only to

manmade bodies of water which neither were originally created in waters of the United

States (such as disposal area in wetlands) nor resulted from the impoundment of waters of

the United States [See Note 1 of this Section.] Waters of the United States do not include

prior converted cropland. Notwithstanding the determination of an area's status as prior

converted cropland by any other federal agency, for the purposes of the Clean Water Act,

the final authority regarding Clean Water Act jurisdiction remains with U.S. EPA.

WATER QUALITY STANDARDS: The Clean Water Act (CWA) defines Water

Quality Standards as “Provisions of state or federal law which consist of designated uses

for the waters of the United States, water quality criteria for waters based upon such uses,

and antidegradation policies. Water quality standards are to protect the public health or

welfare, enhance the quality of water and serve the purposes of the Act.” [40 Code of

Federal Regulations (CFR) section 131.3(i)].

In California, Water Quality Control Plans designate the beneficial uses of waters of the

State and water quality objectives (WQOs) to protect those uses. The Water Quality

Control Plans are adopted by the State and Regional Boards through a formal

administrative rulemaking process, and, upon approval by USEPA, the WQOs for waters

of the United States (generally surface waters) become State water quality standards.

USEPA has established water quality criteria in California for priority pollutants in the

National Toxics Rule and the California Toxics Rule (CTR). The CTR criteria are also

water quality standards.


Alameda Lagoons

Page 7 of 44

EFFLUENT LIMITATIONS: NPDES permits for discharges to surface waters must

meet all applicable provisions of sections 301 and 402 of the CWA. These provisions

require controls that utilize best available technology economically achievable (BAT),

best conventional pollutant control technology (BCT), and any more stringent controls

necessary to reduce pollutant discharge and meet water quality standards.

Title 40, CFR section 122.44 states that if a discharge causes, has the reasonable potential

to cause, or contributes to an excursion (Reasonable Potential) of a numeric or narrative

water quality criterion, the permitting authority must develop effluent limits as necessary

to meet water quality standards. Title 40, CFR section 122.44(k)(3) allows these effluent

limits to be requirements to implement BMPs if numeric effluent limits are infeasible. It

is infeasible for the State Board to establish numeric effluent limitations in this General

Permit, because the application of aquatic pesticides is not necessarily considered a

discharge of pollutants according to the Talent decision. The regulated discharge is the

discharge of residues associated with the application of aquatic pesticides. These include

over-applied and misdirected pesticide product and pesticide residue. At what point the

pesticide becomes a residue is not precisely known and varies depending on such things

as target weed, water chemistry, and flow. Therefore, the effluent limitations contained in

the General Permit are narrative and include requirements to develop and implement this

APAP that describes appropriate BMPs, including compliance with all pesticide label

instructions, and to comply with receiving water limitations.

The BMPs required herein constitute BAT and BCT and will be implemented to

minimize the area and duration of impacts caused by the discharge of aquatic pesticides

in the treatment area, and to allow for the restoration of water quality and protection of

beneficial uses of the receiving waters to pre-application quality following completion of

a treatment event.

Once an aquatic pesticide has been applied to an application area, the pesticide product

can actively treat the target species within the treatment area. During the treatment event,

the aquatic pesticide is at a sufficient concentration to actively kill or control the target

weeds plants or algae. When active ingredient concentrations are below this effective


Alameda Lagoons

Page 8 of 44

concentration, the aquatic pesticide becomes a residue. The minimum effective

concentration, and the time required to reach it, vary due to site specific conditions, such

as flow, target species, and water chemistry. The Receiving Water Limitations require

that an application event does not result in an exceedance of water quality standards in

the receiving water. The receiving water includes:

Anywhere outside of the treatment area at any time, and

Anywhere inside the treatment area after completion of the treatment event.

In recognition of the variability in the temporal extent of a treatment event, the General

Permit does not require it to be discretely defined. Instead, post-event monitoring of the

water is required no more than a week from the time of aquatic pesticide application.

Receiving water limitations are provided in the General Permit and are provided as

follows: The instantaneous maximum receiving water limitations are based on

promulgated water quality criteria such as those provided in the CTR, water quality

objectives adopted by the State and Regional Water Boards in their Basin Plans, water

quality criteria adopted by the California Department of Fish and Wildlife, water quality

standards such as drinking water standards adopted by U.S. EPA or the California

Department of Public Health (CDPH), or the U.S. EPA’s National Recommended

Ambient Water Quality Criteria.

This General Permit provides receiving water limitations based on the lowest water

quality criteria/objectives to protect all designated beneficial uses of the receiving water.

The receiving water limitations in this General Permit are similar as those in Order No.

2004-0009-DWQ, with the exception of copper, which has an update formula to calculate

copper exceedence limits based on the CTR.


Alameda Lagoons

Page 9 of 44

The rationale for each limitation is summarized in the table below:

Notes

1. See Regional Water Boards’ Water Quality Control Plans (Basin Plans) for beneficial use definitions.

2. Public entities and mutual water companies listed in Attachment G are not required to meet this

receiving water limitation during the exception period described in Section VIII.C.10, Limitations

3. For waters in which the salinity is equal to or less than 1 part per thousand 95% or more of the time, the

freshwater criteria apply. For waters in which the salinity is equal to or greater than 10 parts per thousand

95% or more of the time, saltwater criteria apply. For waters in which the salinity is between 1 and 10 parts

per thousand, the applicable criteria are the more stringent of the freshwater or saltwater criteria.

4. For freshwater aquatic life criteria, waters with a hardness 400 mg/L or less as calcium carbonate, the

actual ambient hardness of surface water shall be used. For waters with a hardness of over 400 mg/L as

calcium carbonate, a hardness of 400 mg/L as calcium carbonate shall be used with a default Water-Effect

Ratio of 1.

5. Values should be rounded to two significant figures.

6. This limitation does not apply to the Sacramento River and its tributaries above the State Highway 32

Bridge at Hamilton City. See Table III-1 of the Basin Plan for the Sacramento and San Joaquin River

Basins for copper limitation.


Alameda Lagoons

Page 10 of 44

MONITORING REQUIREMENTS: The General Permit requires dischargers to

comply with the Monitoring and Reporting Program (MRP). The goals of the MRP are

to:

1. Identify and characterize algaecide or aquatic herbicide application projects

conducted by the Discharger;

2. Determine compliance with the receiving water limitations and other

requirements specified in this General Permit;

3. Measure and improve the effectiveness of the APAP;

4. Support the development, implementation, and effectiveness of BMPs;

5. Assess the chemical, physical, and biological impacts on receiving waters

resulting from algaecide or aquatic herbicide applications;

6. Assess the overall health and evaluate long-term trends in receiving water quality;

7. Demonstrate that water quality of the receiving waters following completion of

resource or weed management projects are equivalent to pre-application

conditions; and

8. Ensure that projects that are monitored are representative of all algaecide or

aquatic herbicide applications and methods used by the Discharger.

This APAP was prepared to address the above requirements and those detailed in the

General Permit.

DESCRIPTION OF THE WATER SYSTEM

The South shore lagoon system consists of five individual lagoons linked together by

approximately 3,070 linear feet of 60-inch reinforced concrete pipe (Exhibit C below).

The lagoon system was constructed in the late 1950’s and early 1960’s, when the existing

San Francisco Bay shoreline was filled to create additional single-family residential units,

some multi-family structures, and a few commercial properties. The lagoons are

approximately two miles in length, have a total surface area of approximately 50 acres,


Alameda Lagoons

Page 11 of 44

and vary in depth from one foot at the perimeter walls to approximately eight feet in the

center.


Alameda Lagoons

Page 12 of 44

Lagoon No. 1 extends from Westline Drive (near Shoreline Drive) to Grand Street;

Lagoon No. 2 extends from Grand Street to Willow Street; Lagoon No. 3 extends from

Willow Street to Park Street; Lagoon No. 4 extends from Park Street to Broadway; and

Lagoon No. 5 extends from Broadway to Bayview Drive (near Court Street).

The lagoons are supplied with water from the San Francisco Bay by a 3,000-gallon per

minute pump housed in a station located near the Westline Drive/Shoreline Drive curve.


Alameda Lagoons

Page 13 of 44

The pump only operates during high tides because of the shallow location of the intake

structure. Once the water is pumped into the westerly-most lagoon, it flows through the

lagoons by gravity and returns to the Bay at the easterly-most lagoon. The water level is

controlled by two weir structures with sluice gates, the Willow weir located at the end of

Lagoon No. 2 and the Bayview weir located at the end of Lagoon No. 5 at the outlet

structure. These structures allow the water level to be manually raised or lowered to the

required height. Water is maintained at a constant level except during the winter rainy

season and for annual maintenance.

The lagoons serve as a private, recreational area for the enjoyment of residents living

along the lagoons, as well as a channel for storm water during periods of rain. The City

of Alameda maintains the lagoons for purposes of storm drainage, private recreational

use, and aesthetics.

During the winter months there is an increase in turbidity and the amount of debris

entering the lagoons. Migratory waterfowl also frequent the lagoons as well as resident

birds. Egrets, herons, and various ducks are the primary migratory waterfowl. Resident

birds consist mostly of mallards, Canadian geese, and coots.

The Alameda West Lagoon Home Owners’ Association (AWLHOA), made up of the

residents fronting the south side of the lagoons, is the record title owner of the lagoon

system, and the City has a perpetual easement over it for maintenance purposes. As such,

the City consults with the AWLHOA on the maintenance and monitoring of the lagoon

system.

The Alameda Lagoons have been experiencing nuisance growths of submerged aquatic

vegetation as well as planktonic and filamentous algae blooms that have impacted the

beneficial uses of the system that include storm water retention, recreational use, and

aesthetics.


Alameda Lagoons

Page 14 of 44

As mentioned above the lagoons are approximately two miles in length, have a total

surface area of approximately 50 acres, and vary in depth from one foot at the perimeter

walls to approximately eight feet in the center.

DESCRIPTION OF THE TREATMENT AREA

Throughout the spring and summer the lagoons are impacted by nuisance growths of

submerged aquatic vegetation and algae. All of the lagoons are fairly shallow so aquatic

weed growth can occur throughout the entire area of the lagoons The aquatic weed most

commonly controlled in the Alameda lagoons is Widgeon Grass (Ruppia maritime L.)

The lagoons also get planktonic and filamentous algae blooms. Water volume of the area

targeted for submerged aquatic plant control will vary based on water levels within the

system, but typical water depths in the treatment areas will average approximately 4-6

feet. The acreages for each lagoon are outlined in the diagram above.


Alameda Lagoons

Page 15 of 44

The Alameda Lagoons contain two weir structures and sluice gates. The gates are

primarily left open as the lagoons operate as a flow through system. When applications

are performed these gates will be closed and inspected prior to the treatments to ensure

that they are in good working condition and not open.

APPLICATION SCHEDULE

The City of Alameda and or applicator will provide a phone number or other specific

contact information to all persons who request the City of Alameda and or applicator’s

application schedule and will inform the requester if the schedule is subject to change.

Information may be made available posting it on a well-known website.

PUBLIC NOTICE REQUIREMENTS

Every calendar year at least 15 days prior to the first application of algaecide or aquatic

herbicide, the City of Alameda and or the applicator will notify potentially affected

public agencies. The notification will include all of the information outlined in Section

VIII. B.

AQUATIC PESTICIDES AND ADJUVANTS EXPECTED TO BE USED AND

APPLICATION METHODS

Provided in the table below are the aquatic herbicides and algaecides that may be used in

the aquatic plant and algae control program for the Alameda Lagoons. The need for

treatments is based on aquatic weed growth, algal counts and visual monitoring.

Water Use Restrictions

Herbicide*

Algaecide*

Days for

Swimming

Days for Fish

Consumption

Days for Irrigation

of Turf/Food Crops

Degradation

Byproducts

Cutrine Plus (Copper as

elemental 9.0%)

0 0 0 None

Reward (Diquat

dibromide)

0 0 3-5 None

Hydrothol 191 (Mono(N,N-

dimethylalkylamine

salt of endothall)

0 0 0 None


Alameda Lagoons

Page 16 of 44

Green Clean

Liquid (Hydogen

Dioxide)

0 0 0 None

Nautique (Copper

Carbonate 15.9%)

0 0 0 None

Cygnet Plus

(Adjuvant) (Limonene)

(Methylated

Vegetable Oil)

Alkyl hydrooxypoly

oxyethylene)

0 0 0 None

*Refer to Product Labels and MSDS’s for Further Information

PAK27, GreenClean Liquid, Hydrothol 191, and Cutrine Plus are all of the algaecides

used to control planktonic algae in the Alameda Lagoons. Reward and Nautique are all of

the herbicides used to control submerged aquatic weeds in the water column. The Cutrine

Plus and Nautique have copper based active ingredients. Based on the City of Alameda’s

Integrated Pest Management Policy (IPM) the City does not want Copper based products

used in the lagoons, unless they are used when all other alternatives do not work or if

there is an emergency situation. Therefore the applicator will not use these products

without first getting approval from the City of Alameda and only when alternatives do

not work or when there is an emergency.

Aquatic herbicide and algaecide applications are performed utilizing Best Management

Practices (BMP’s) by licensed personnel in accordance with a Pest Control

Recommendations (PCR) issued by a State of California, Department of Pesticide

Regulation (DPR) Pest Control Advisor. Clean Lakes, Inc. performs aquatic plant

control applications and water quality monitoring. Clean Lakes, Inc.’s application staff

hold State of California, Department of Pesticide Regulation (DPR), Pest Control

Advisor licenses and Qualified Applicator Licenses or Certificates. Applications are

performed from a boat as surface or subsurface applications based on the target species.

Alternatively, if a granular product is used, an educator or blower application system is

used to apply the granular formulation. Aquatic herbicide applications are carried out

using GPS technology to track treatment location, date, time and boat speed.


Alameda Lagoons

Page 17 of 44

FACTORS INFLUENCING ALGAE AND WEED CONTROL

The decision to implement aquatic vegetation control treatments is based on the plant’s

growth stage in the spring of each season, and re-evaluated during the summer months.

Planktonic and filamentous algae treatments are based on growth as well their nuisance

level as they develop, typically through the spring and summer months. When

submerged vegetation or planktonic algae is treated in an early growth stage, there is less

plant biomass that is controlled, and decomposing in the system, which helps reduce and

protect against impacts to dissolved oxygen depletion from decomposing biomass. Based

on nuisance levels of aquatic plant growth, and or algae densities and their potential to

impact beneficial uses of the lagoon system, a Pest Control Advisor (PCA) will review

control options. Based on the PCA’s findings, a Pest Control Recommendation (PCR)

will be developed for aquatic pesticide applications.

Aquatic herbicide and algaecide treatments are determined based on the following

characteristics:

Clean Lakes Inc. regularly monitors the lagoons for algal growth. When the

threshold (Algae Count) is reached Clean Lakes Inc. provides an algaecide

treatment. Aquatic weeds are continually monitored throughout the growing

season. When aquatic weed growth reaches a nuisance level Clean Lakes Inc.

provides aquatic weed treatments.

The surface area of the Alameda Lagoons is approximately 50 surface acres.

The water volume of the Alameda Lagoons is calculated to be approximately 200

acre feet (50 surface acres x 4’ foot average depth)

The water volume of the area targeted for aquatic weed control is calculated by

determining the surface acreage of the treatment area and then multiplying it by

the average depth in the treatment plot. For example: A two (2) acre plot with an

average depth of six feet would result in a 12 acre ft. water volume.


Alameda Lagoons

Page 18 of 44

Water movement through the system is supplied with water from the San

Francisco Bay by a 3,000-gallon per minute pump housed in a station located near

the Westline Drive/Shoreline Drive curve. The pump only operates during high

tides because of the shallow location of the intake structure. Once the water is

pumped into the westerly-most lagoon, it flows through the lagoons by gravity

and returns to the Bay at the easterly-most lagoon.

MONITORING AND REPORTING PROGRAM

Monitoring Requirements: The General Permit requires that dischargers comply with

the Monitoring and Reporting Program (MRP) outlined in the General Permit. The goals

of the MRP are to:

1. Identify and characterize algaecide or aquatic herbicide application projects

conducted by the Discharger;

2. Determine compliance with the receiving water limitations and other

requirements specified in this General Permit;

3. Measure and improve the effectiveness of the APAP;

4. Support the development, implementation, and effectiveness of BMPs;

5. Assess the chemical, physical, and biological impacts on receiving waters

resulting from algaecide or aquatic herbicide applications;

6. Assess the overall health and evaluate long-term trends in receiving water

quality;

7. Demonstrate that water quality of the receiving waters following completion of

resource or weed management projects are equivalent to pre-application

conditions; and

8. Ensure that projects that are monitored are representative of all algaecide or

aquatic herbicide and application methods used by the Discharger.

General Monitoring

1. The Alameda Lagoons aquatic weed treatments will occur as full lagoon, partial

lagoon and spot treatments. Since the Alameda Lagoons receive water

continuously from the San Francisco Bay, sample locations will be established in

areas not influenced by incoming water according to pre and post event

monitoring schedules outlined in the General Permit. The Event Monitoring


Alameda Lagoons

Page 19 of 44

samples will be collected at the outlet of the lagoon while the pre and post event

monitoring will occur within the treatment area.

2. Algaecide and aquatic herbicide application practices will be established based on

the Pest Control Recommendations (PCR) from a DPR licensed Pest Control

Advisor (PCA). Aquatic plant and algae growth will be evaluated to determine

the potential for creating impacts or nuisances to lake use and management prior

to any treatments. The aquatic herbicide and or algaecide labels directions are

factored into treatments to determine timing and application rates. Application

practices utilize the most appropriate application technique to comply with BMP’s

via surface or subsurface treatment methods. GIS and GPS technology allow a

high level of precision when calculating area and for guiding treatments,

respectively.

3. Aquatic herbicides and algaecides are registered by the US Environmental

Protection Agency (USEPA) nationally, and the CA Department of Pesticide

Regulation (CADPR) within California. Manufacturers of products must provide

information to the USEPA for registration or re-registration purposes that includes

information with regard to transport, environmental fate and effects of algaecides

and aquatic herbicides. Algaecides and aquatic herbicides planned for use in the

Alameda Lagoons are registered for use by both the USEPA and the CADPR.

Detailed information about transport, fate and effects of algaecides and aquatic

herbicides are addressed in USEPA’s Re-registration Eligibility Decisions. (RED)

Documents for a few of the active ingredients are as follows, the rest can be found

on the EPA website:

Cutrine Plus/Captain (copper):

http://www.epa.gov/oppsrrd1/REDs/copper_red.pdf

Reward (diquat dibromide):

http://www.epa.gov/oppsrrd1/REDs/0288.pdf

Green Clean (sodium carbonate peroxyhydrate):

http://www.epa.gov/pesticides/chem_search/reg_actions/registration/decisi

on_PC-128860_16-Sep-02.pdf

4. Designated Beneficial Uses for the Alameda Lagoons include boating, swimming,

fishing, storm water detention, and aesthetics. Cumulative and indirect effects of

http://www.epa.gov/oppsrrd1/REDs/copper_red.pdf

http://www.epa.gov/oppsrrd1/REDs/0288.pdf

http://www.epa.gov/pesticides/chem_search/reg_actions/registration/decision_PC-128860_16-Sep-02.pdf

http://www.epa.gov/pesticides/chem_search/reg_actions/registration/decision_PC-128860_16-Sep-02.pdf


Alameda Lagoons

Page 20 of 44

algaecides and aquatic herbicides are discussed in USEPA Re-registration

Eligibility Documents (RED) discussed in item 3 above. No known negative

impacts have been observed from aquatic herbicide and or algaecide applications

in the Alameda Lagoons.

5. The potential for algaecide and aquatic herbicide applications leading to

designated use impacts is unlikely since DPR licensed Qualified Applicators

implement the treatments based on a Pest Control Recommendation (PCR) and by

following herbicide label directions. Misuse, over use, or use of incorrect

products are not expected to occur due to the preparations and planning that take

place prior to implementing a treatment.

6. No known or potential impacts from algaecides and aquatic herbicide applications

on water quality are anticipated based on following herbicide label requirements,

the infrequent applications that are anticipated to take place, and the short

duration that algaecides or aquatic herbicides are present in the water column. A

Risk Assessment is provided for each of the active ingredients in the USEPA

REDs discussed in Item 3.

7. Pre and post water quality sampling stations are sufficient to assess algaecide or

aquatic herbicide applications due to the small nature of the lake, the size of the

treatments, and the relative ease that sample locations can be visited.

8. The monitoring plan prepared for this APAP is described below.

Receiving Water Monitoring

Treatment Maps: For each application at each site, a treatment map will be

developed with a convenient scale showing the application area, treatment area,

immediately adjacent untreated areas (if entire water body is not treated), and water

bodies receiving treated water. Information about surface area and/or volume of the

application area, treatment area, and any other information used to calculate dosage

and quantity of each pesticide used at each application site will be included with the

algaecide and aquatic herbicide application monitoring log forms (see below).

Sampling locations will be noted on the treatment map and global positioning systems


Alameda Lagoons

Page 21 of 44

(GPS) coordinates for each sampling site will be noted on application monitoring log

forms.

Control Structure Inspections: Prior to every application, an inspection of the

integrity of the weirs and sluice gates will be performed to ascertain that treated water

does not unintentionally get discharged from the lagoon system.

Aquatic Pesticide Monitoring Frequency: Samples will be collected from a minimum

of six application events for each active ingredient. If there are less than six

application events in a year, samples will be collected during each application event

for each active ingredient. If the results from six consecutive sampling events show

concentrations that are less than the receiving water limitation/trigger for an active

ingredient, sampling shall be reduced to one application event per year for that active

ingredient. If the yearly sampling event shows exceedence of the receiving water

limitation/trigger for an active ingredient, then sampling shall return to six application

events for that active ingredient.

Aquatic Pesticide Monitoring: The following monitoring activities will be performed

for a minimum of six application events, or as many applications as occur in a year if

there are less than six application events, at representative locations:

1. Background Monitoring. Background monitoring samples will be collected

upstream at the time of the application event or in the application area just prior to

(up to 24 hours in advance of) the application event.

2. Event Monitoring. Event monitoring samples will be collected immediately

downstream of the treatment area in flowing waters or immediately outside of the

treatment area in non-flowing waters immediately after the application event, but

after sufficient time has elapsed that treated water would have exited the treatment

area.

3. Post-Event Monitoring. Post-event monitoring samples will be collected within

the treatment area within one week after application.


Alameda Lagoons

Page 22 of 44

Sample Analysis: All samples requiring laboratory analyses will be collected and

analyzed by a laboratory certified for such analyses by the California Department of

Health Services. All analyses will be conducted in accordance with the latest edition

of “Guidelines Establishing Test Procedures for Analysis of Pollutants” (Guidelines),

promulgated by the U.S. Environmental Protection Agency (USEPA) (Title 40 Code

of Federal Regulations part 136). Field analysis for the parameters of temperature,

dissolved oxygen (DO), electrical conductivity, and pH will be performed using a

Portable Multi-Parameter Meter (YSI or equivalent) with a sufficiently long probe

cable, and will be maintained and calibrated at regular intervals according to the

manufacturer specifications. Secchi Disk measurements will be performed using a

standard Secchi disk. Water samples collected for laboratory analysis will be

accompanied with a completed chain of custody form identifying the chemical

constituents requiring analysis, and delivered to a State of California Certified

Laboratory per the NPDES Permit requirements.


Alameda Lagoons

Page 23 of 44

Monitoring Parameters: The following parameters will be collected or analyzed:


Alameda Lagoons

Page 24 of 44

Sampling Procedures: Samples will be collected using sampling procedures which

minimize loss of monitored constituents during sample collection and analysis to

maintain sample integrity.

Sampling protocols: Samples will be retrieved, stored, recorded, and shipped to a

third party laboratory using the following methods and precautions. Any deviation

from these methods and precautions will be recorded and explained.

Materials for in field sampling:

1) New sampling bottles, one per sample with sample ID label.

2) Cooler(s) sufficient to hold ample bottles, with ice- or gel-packs

3) Plastic gloves

4) Subsurface grab sampler

5) Depth finder, marked pole, Secchi Disk (cord marked with half foot

increments), or water quality monitoring probe with depth sensor.

6) Instrument(s) for measurement of temperature, pH, dissolved oxygen,

hardness, electrical conductivity, depth.

7) GPS for sample location coordinates.

8) Field data sheets and clipboard

9) A clean boat and a transport vehicle

Method to collect a single sample: Samples will be simple grab samples.

1) When approaching a sampling location, care will be taken to not stir up

sediments and to approach from downstream or down wind direction. If

anchoring is required, lower anchor gently.

2) Immediately prior to collecting the sample, the sample bottle label details will

be completed (i.e. date, time, sample collector…)

3) When taking the sample, the cap will be left on the bottle until it is at three

feet of depth or at midpoint in the water column if less than three feet, per the

monitoring forms outlined below.

4) Once the bottle is at the appropriate depth, the cap will be removed below the

surface. Stirring of the sediments will be avoided.

5) The bottle will be rinsed with sample water and emptied twice, then filled

completely

6) Once the bottle is full, it will be capped.

7) The bottle will be placed in the appropriate cooler. The bottles will be kept in

contact with ice packs

8) Other water quality measurements will be taken and recorded

9) The Water Sampling Data Sheet will be filled out with information for the

sample


Alameda Lagoons

Page 25 of 44

10) In the office, the bottle will be placed into a refrigerator, unless samples are

taken immediately to a laboratory.

SPECIAL NOTES:

1) For a spot treatment, a sketch map will be made showing the site of the

treatment and the location of the sample relative to the treated area

2) In addition, a Global Positioning System (GPS) reading will be taken, noting

the latitude and longitude in WGS 1984 datum to six decimal places and

recording on the application monitoring form.

Submitting sample to lab:

1) Samples will be submitted within 48 hours of sample collection or sooner to a

laboratory.

2) Samples will be packed in a cooler with ice packs between each bottle

3) Chain of Custody (COC) form will be prepared to include details on the

sample bottle labels.

4) If the samples are shipped to the lab, the pick-up person will sign the COC

and a copy will be made before sending out the shipment. If the samples are

delivered to the lab, the delivering person will have the receiving person sign

the COC form and provide a copy before turning over the shipment.

Retention of Records: Records of all monitoring information including all

calibration and maintenance records, copies of all reports required by the General

Permit, and records of all data used to complete the application per the General

Permit will be retained. Records will be maintained for a minimum of three years

from the date of the sampling event. This period may be extended during the

course of any unresolved litigation regarding a discharge, or when requested by

the appropriate Regional Board Executive Officer.

Monitoring Records: Records of monitoring events will include the following

information:

a. The date, exact place, and time of sampling or measurements;

b. The individuals who performed the sampling or measurements;

c. The date’s analyses were performed;

d. The individuals who performed the analyses;

e. The analytical techniques or method used; and

f. The results of such analyses.


Alameda Lagoons

Page 26 of 44

The following forms will be used to collect and track information required for each

treatment event as required by the Genera Permit:


Alameda Lagoons

Page 27 of 44

CLEAN LAKES, INC. AQUATIC WEED CONTROL

NPDES AQUATIC PESTICIDE APPLICATION LOG

Date of Application: Location: App. Start Time:

App. Stop Time:

Applicator Name: APAP Certification:

Attach map showing application area, treatment area, immediately adjacent untreated area, and water bodies receiving

treated water.

Discharge Gates or Control Structures

Name Date Closed Time Closed Date Opened Time Opened

1.

Calculations to Determine Opening and Closures:

2. Provide information on surface area and/or volume of application area and treatment area and other information used

to calculate dosage and quantity of each pesticide used at each application site:

2.a Application Area – Surface Area: 2.b Application Area – Volume:

2.c Treatment Area – Surface Area: 2.d Treatment Area – Volume:

2.e Dosage and Quantity Information for each pesticide used:

Application Details

Plot Number Area (ac. or sq. ft.) Average

Depth

Product Product Quantity Concentration or Rate

For additional treatment areas use additional forms.


Alameda Lagoons

Page 28 of 44

AQUATIC WEED CONTROL

NPDES RECEIVING WATER MONITORING

Visual Observation Form (Background Monitoring)

Monitoring Date: Location: Sampled by:

Monitoring Area Description (pond, lake, waterway channel,…):

Site Conditions/Appearance of Waterway

Floating or suspended matter:

Present Absent

Discoloration:

Present Absent

Bottom deposits:

Present Absent

Aquatic life:

Present Absent

Visible films, sheens or coatings:

Present Absent

Fungi, slimes, or objectionable growths:

Present Absent

Potential nuisance conditions:

Present Absent

Weather conditions and other observations (fog, rain, wind, wind direction…):

Visual Observation Form (Event Monitoring)





Present Absent

Discoloration:

Present Absent

Bottom deposits:

Present Absent

Aquatic life:

Present Absent


Present Absent


Present Absent


Present Absent


Visual Observation Form (Post Event Monitoring)





Present Absent

Discoloration:

Present Absent

Bottom deposits:

Present Absent

Aquatic life:

Present Absent


Present Absent


Present Absent


Present Absent



Alameda Lagoons

Page 29 of 44

AQUATIC WEED CONTROL

NPDES RECEIVING WATER MONITORING Physical and Chemical Monitoring Location: ___________________Sampled by:_____________________

(Physical and chemical monitoring required for six (6) applications for each type of pesticide at each waterbody site. See General Permit)

1. Background Monitoring Parameters (u/s or at treatment area up to 24 hours before or at time of treatment) Date:

Physical Sample Type

(3 feet below water surface

or mid depth if < 3 feet)

Temperature (F) 1 Turbidity (NTU)

2 Electrical Conductivity (µmhos/cm)

2

Chemical Sample Type



Active Ingredient (µg/l) Nonylphenol (µg/l) 3 pH

2

Dissolved Oxygen (mg/L) 2 Hardness (CaCO3)

4 GPS latitude and longitude coordinates

2. Event Monitoring Parameters (d/s or immediately adjacent to treatment area immediately after application) Date:






2





2



3. Post Event Monitoring Parameters (w/i treatment area + immediately d/s in flowing water or adjacent to

treatment area w/i 1 week) Date:






2





2



1 Field Test;

2 Field or Laboratory Test;

3 Required when nonylphenol is used;

4 Required for copper applications.


Alameda Lagoons

Page 30 of 44

Device Calibration and Maintenance: All monitoring instruments and devices that will be

used by the discharger to fulfill the prescribed monitoring program will be properly

maintained and calibrated as necessary to ensure their continued accuracy.

Reporting

Annual Report

All reports will be submitted to the appropriate Regional Board Executive Director or Deputy

Director. All reports submitted in response to the Water Quality Order will comply with the

provisions stated in the Standard Provisions (Attachment B) and Monitoring and Reporting

Program (Attachment C), of the General Permit. The Annual reports will contain the

following information:

An executive summary discussing compliance or violation of the General Permit, and

the effectiveness of the APAP to reduce or prevent the discharge of pollutants

associated with algaecide and aquatic herbicide applications;

A summary of monitoring data, including the identification of water quality

improvements, or degradation as a result of the algaecide or aquatic pesticide

application, if appropriate, and recommendations for improvements to the APAP

(including proposed best management practices (BMPs) and monitoring program

based on the monitoring results). All receiving water monitoring data will be

compared to receiving water limitations and receiving water monitoring triggers;

Identification of BMPs currently in use and a discussion of their effectiveness in

meeting the requirements in this General Permit;

A discussion of BMP modifications addressing violations of this General Permit;

A map showing the location of each treatment area;

Types and amounts of algaecides and aquatic herbicides used at each application

event;


Alameda Lagoons

Page 31 of 44

Information on surface area and/or volume of treatment areas and any other

information used to calculate dosage, concentration, and quantity of each algaecide

and aquatic herbicide used;

Sampling results will indicate the name of the sampling agency or organization,

detailed sampling location information (including latitude and longitude or

township/range/section if available), detailed map or description of each sampling area

(address, cross roads, etc.), collection date, name of constituent/parameter and the

concentration detected, minimum levels, method detection limits for each constituent

analysis, name or description of water body sampled, and a comparison with

applicable water quality standards, and a description of the analytical QA/quality

control plan. Sampling results will be tabulated so that they are readily discernible;

and

A summary of the algaecide and aquatic herbicide application logs.

24 Hour Report and Five Day Reporting

The City of Alameda and or applicator will orally report any non-compliance. This includes any

unexpected or unintended effect of the use of an algaecide or aquatic herbicide that may danger

health or the environment. This information will be provided orally within 24 hours from the

time the City of Alameda or applicator becomes aware of the circumstances. A written report of

the non-compliance will be provided within five (5) days of the time the City of Alameda and or

applicator becomes aware of the noncompliance. The 24 hour report as well as the 5 day written

report will follow the format in Attachment C.

Data Storage: All data will be recorded on supplied forms. At the end of each day, all data

forms will be double copied. The original will stay in specified notebooks. The first copy will

be stored in a file cabinet. The second copy will be stored and shipped with the samples.


Alameda Lagoons

Page 32 of 44

Quality Assurance Audits and Personnel: The discharger will provide a Quality Assurance

Officer and the Certified Laboratory will provide one Quality Assurance Officer. In addition, the

Water Quality Control Board is welcome to provide third party validation of the sampling

procedures.

Methods for Determination of Other Water Quality Parameters: Water quality parameters such

as pH, dissolved oxygen, and temperature will be measured by appropriate instrumentation

within the manufacturer’s tolerances. These parameters will be measured at the same sites where

water samples for aquatic pesticides are retrieved. These parameters will be measured at the

same depths from which the water samples for aquatic pesticides are retrieved, within +/- 0.5

meters. Data and deviations will be recorded on specified forms and/or lab notebooks.

Methods for Data Summarization, Analysis, Review, and Reporting: All data will be included in

the final report. The final report will also contain narrative and numerical summaries as

appropriate. Final data reports will also be reviewed by a Quality Assurance Officer.

Training on Sampling Techniques: All personnel performing water sampling will have been

trained before water sampling is scheduled to begin, a training session will be held reviewing

sampling technique; equipment and instrument calibration, maintenance, and operation; sample

storage and delivery; the proper use of COC and other forms; and other records and deviations.

DESCRIPTION OF PROCEDURES TO PREVENT SAMPLE CONTAMINATION

Measures will be taken to prevent sample collection contamination from persons, equipment and

vehicles associated with algaecide and aquatic herbicides application, as follows:

Background monitoring sample collection will be carried out prior to application

equipment or algaecides/aquatic herbicides being loaded into a boat. Background

monitoring sampling, as well as post event monitoring sampling (within one week), if

appropriate, sampling may be carried out from shore at a dock within the sampling areas

to eliminate the potential for contamination. Sampling equipment, with particular

emphasis on cooler and sample bottles will be transported separately from algaecides or


Alameda Lagoons

Page 33 of 44

aquatic herbicides and application equipment on the day of the application event.

Background monitoring will take place immediately prior to the application event.

For event monitoring, sampling will be carried out after application equipment and all

application related equipment and devices including personal protection equipment (PPE)

used during the application has been removed from the boat, if no other boats are

available to support sampling efforts. If there are multiple personnel supporting

applications, one will be designated the sample collector while the other will be

responsible for boat operation. Hands will be washed with soap and clean potable water

before handling sampling equipment, cooler and sample bottle. During sample bottle

handling and sample collection, disposable rubber gloves will be used to collect a water

sample. The pre labeled sample bottle will be completed with time and date of sample

collection immediately after removing from the sample cooler and replaced in the cooler

immediately after sample collection. Once sampling has been completed, water samples

will be delivered immediately to the laboratory, if possible. If background and event

samples cannot be delivered the same days, sample bottles will be stored in a clean

refrigerator at the office until samples can be delivered the next business day.

DESCRIPTION OF BEST MANAGEMENT PRACTICES (BMPs) TO BE

IMPLEMETED:

A variety of approaches will be utilized to minimize the impacts of aquatic pesticides used while

still achieving their goals.

Techniques that help reduce pesticide impacts include:

o Non-pesticide control methods as outlined below (Alternatives) have been

attempted or considered.

o Pre Treatment surveys are carried out to identify potential treatment areas and

timing

o Adjustments will be made to treatment protocols based upon survey results

o Choice of pesticides based on toxicity

o All attempts will be made to time treatments when no water is being discharged

from the lake system


Alameda Lagoons

Page 34 of 44

o Aquatic Pesticide use rates will be per the EPA label and will be limited to ensure

compliance with Receiving Water Limitations

o Partial water body treatments or split treatments will be utilized to minimize

impacts that might otherwise occur

From the aquatic herbicides available, the most effective and safest options have been

selected for use in this program. The Pest Control Advisor (PCA) and Herbicide

application personnel (Qualified Applicators) know the strengths and weaknesses of the

various available options, and take them into consideration when choosing a treatment

protocol for a specific site.

In order to avoid inadvertent or accidental soil or water contamination with aquatic

pesticides, application personnel follow the storage, transport, and spill control

procedures per USEPA and DPR rules, regulations and label instructions.

Over application is avoided by following the specific product labels for the aquatic

pesticides used in the program. Algaecide and aquatic herbicide quantities required for

each treatment are calculated at the office and only sufficient material to carry out the

treatment is transported for the day’s application. Application equipment is routinely

cleaned and maintained, and all label directions and DPR guidelines are followed as to

acceptable application methods as well as weather conditions. Surface applications are

not made in winds above 10 miles per hour.

The various BMP’s being implemented ensures that the Aquatic Vegetation Control

Program will meet the requirements of the general NPDES Permit for the use of aquatic

pesticides.

Licensing: All crew leaders and biologists that apply or supervise the application of

aquatic pesticides are certified and or licensed by DPR.

Notification: As detailed elsewhere in this document, whenever pesticides are used that

might lead to damage to irrigated landscape (the most severe potential impact on

beneficial uses caused by the program), potentially affected users in the area are informed


Alameda Lagoons

Page 35 of 44

of the treatments so that means can be taken to avoid using the treated water for irrigation

purposes.

Site Evaluations: As has been detailed in this section and elsewhere, both preliminary

and secondary site evaluations are a major aspect of the program, as represented by the

extensive surveying carried out by the field crews.

Alternative Treatments: Staff considers a number of potential alternative control

strategies in every situation, and will make use of non-herbicide options when conditions

are suitable.

Treatment Conditions: Every application is made according to label directions and other

requirements as directed by DPR or the agricultural commissioner, which not only

specify the amounts and situations where pesticides may be applied, but the atmospheric

and environmental conditions under which they may be applied. If there are conditions

where it is determined that the treatment would be ineffective, application staff wait for

other conditions or use a different treatment method.

Post-treatment: Surveys are also carried out for post-treatment assessment of treatment

efficacy and non-target impacts. Survey crews are instructed to look for possible non-

target impacts that can be seen with the naked eye, such as dead fish or damage to plants

on the shoreline.

The applicator follows all pesticide label instructions and any Use Permits issued by a

CAC;

The discharger’s applicators are licensed by DPR, or work with or under the supervision

of someone who is licensed;

The discharger’s applicators comply with effluent limitations

The discharger’s applicators will follow this Aquatic Pesticide Application Plan (APAP);

RNorman

Sticky Note


Alameda Lagoons

Page 36 of 44

The discharger’s applicator’s comply with applicable receiving water limitations; and

The discharger’s applicators will comply with the monitoring and reporting requirements

outlined in this APAP.

Aquatic Pesticide Use Requirements:

License Requirements. Dischargers applicators will be licensed by DPR if such

licensing is required for the aquatic pesticide application project

Application Requirements. The pesticide will be consistent with FIFRA pesticide label

instructions and any Use Permits issued by CACs.

Application Schedule. When requested, the City of Alameda and or Applicator will

provide a phone number to persons who request the discharger’s application schedule.

The City of Alameda and or Applicator will provide the requester with the most current

application schedule and inform the requester if the schedule is subject to change.

Information may be made available by electronic means.

Public Notice Requirements. Every calendar year, at least 15 days prior to the first

application of aquatic pesticides, the City of Alameda will notify potentially affected public

agencies. The City of Alameda will post the notification on its website if available. The

notification will include the following information:

1. A statement of the discharger’s intent to apply algaecide or aquatic herbicide(s);

2. Name of algaecide and or aquatic herbicide to be used;

3. Purpose of use;

4. General time period and locations of expected use;

5. Any water use restrictions or precautions during treatment; and

6. A phone number that interested persons may call to obtain additional information

from the Discharger.


Alameda Lagoons

Page 37 of 44

EXAMINATION OF AQUATIC VEGETATION CONTROL ALTERNATIVES

All appropriate aquatic plant management technologies within the context of the identified

beneficial uses and impacted areas of the lagoons have been evaluated, and include all available

cultural, biological, mechanical, and aquatic pesticide formulations.

Aquatic weed and algae control options have been broken down into four basic categories that

include:

Watershed Management

Biological Control

Physical and Mechanical Control

Aquatic Algaecides and Herbicides

A discussion on each of the options follows:

Watershed Management and the Runoff Impacts:

Watershed management is one of the most important control parameters as it deals with limiting

nutrients and runoff into a lake system from the watershed. It entails implementing practices in

the watershed that will support the reduction of nutrient and other pollutant runoff into the lake

system. In natural areas, 10 % is runoff and 50 to 60 % is direct infiltration (Runoff Coefficients

for the Rational Method of Estimating Rainfall (McCuen, 1989)).

Runoff Impacts

o Non-point source pollution poses the most serious threat to the water quality of

lakes.

o Non-point pollution in runoff includes: sediments, oil, anti-freeze, road salt,

pesticides, yard wastes and pet and waterfowl droppings.


Alameda Lagoons

Page 38 of 44

Nutrient Effects

o Increase in algae blooms

o Odor problems

o Depletion of oxygen supply

o Fish kills

o Decrease in water clarity

o Increase in the amount of rooted aquatic plants growing in the shallow waters of a

lake

o Reduction in the recreational value of the lake hinders boating, fishing, and

reduces overall aesthetics of the lake

Eutrophication Process and Impacts:


Alameda Lagoons

Page 39 of 44

Impacts of Eutrophication

o Fish kills due to low oxygen or high metals

o Taste and odor problems, resulting in an increase in water treatment costs

o Floating algae mats, decaying vegetation

o Increased littoral vegetation in shallow areas

o Mobilization of sediment bound metals and ions during anoxic conditions (e.g.,

copper, ammonia, iron, sulfur,

phosphorus)

o Increased temperature

o Reduced water clarity

o Nuisance algal blooms

o Reduced dissolved oxygen in

hypolimnion

o Earlier onset and/or longer duration of periods of anoxia in hypolimnion

Several tools are available to control the use and misuse of the land surrounding the lake that

includes:

Comprehensive Plans to guide long-term growth;

Storm Water and Surface Water Management Planning that considers data collection,

land use, system site considerations, and design criteria for structures in setting goals for

watershed runoff; and Rules for Lake Uses such as where, when and how a lake can be

used recreationally to control shoreline erosion, nutrient recirculation and overuse.

Other administrative alternatives may include shoreline erosion and sedimentation

control management programs. Education is still probably the best way to combat water

quality issues.


Alameda Lagoons

Page 40 of 44

Non-structural alternatives: best management practices, such as buffer strips around water bodies

to filter out sediments and reduce nutrients, are examples of non-structural alternatives. Chemical

inactivation/precipitation of in-lake phosphorus, chemical control of algae, dredging of

accumulated sediments, and mechanical harvesting of aquatic vegetation are additional

examples.

Structural alternatives: Storm water detention basins and wetland treatment systems are

structural alternatives that detain runoff to control peak flow rates and control downstream

flooding. They also allow pollutants to settle out of the water before reaching the lake.

Diversions routing storm water away from the lake and in-lake aeration systems to oxygenate the

water are other structural alternatives

Watershed Management

The City of Alameda currently has a Watershed Management Plan in place that helps reduce the

impacts from the areas surrounding the lagoons. The City is actively involved in reviewing new

and improved methods to improve the lagoons and is always updating their watershed

management practices. One of the most recent additions to this program was the addition of

three new trash capture devices to three different locations that drain into the lagoons. These

devices not only capture trash but also organic debris that can contribute to the nutrient load in

the lagoons. The City has plans to install additional units in the near future as well. The

Watershed Management Plan alone has not proven to provide enough nutrient limitation to avoid

aquatic weed growth and planktonic and filamentous algae blooms.

Biological Control

There are very few biological control options for eliminating aquatic weeds and algae. One

option used in smaller water bodies is treatment with microbes and beneficial bacteria that


Alameda Lagoons

Page 41 of 44

digests organic wastes generated by animal and plant life in the body

of water. thus reducing the bottom sludge layer which provides

nutrients to the water bodies. This option is currently used in the

Alameda Lagoons (Cygnet Mukkbuster) to reduce the amount of

organic waste and sludge and it also works well on the odor issues that

emanate from these same waste materials.

Physical

Aeration & Water Quality Alteration: Aeration has been used for decades to circulate water and

increase Dissolved Oxygen within lake and pond systems. In stratified lake systems where the

bottom layers are anoxic during the summer months, a properly designed aeration system will

limit nutrient recycling by supporting aerobic bacteria that support

nutrient breakdown in bottom waters and the hydrosoil. Aeration has

proven to be a successful tool for reductions in planktonic algae growth

in lakes and reservoirs. Systems vary in size and style from fountains to

bottom bubbler diffuser type systems to hypolimnetic units that

oxygenate the lower water below the thermocline. Aeration is an option

in the lagoons and would likely help in some of the areas that don’t

receive a lot of water turnover. However the pump induced flow through

of water going through the lagoons does a good job of aerating and

flushing the system.

Shading/Light Attenuation:

A basic environmental manipulation for algae control is light reduction or attenuation. Organic

dye can be added to a lake or pond system and is usually a blend of blue and yellow dyes

specifically designed to screen or shade portions of the sunlight spectrum (red-orange and blue-


Alameda Lagoons

Page 42 of 44

violet) required by underwater aquatic plant and algae growth. This action effectively inhibits

photosynthesis required for algae growth. Aquashade or a generic such as Cygnet Select is

primarily effective at depths of 2 feet or greater.

Aquashade is non-corrosive and will not stain

bathing suits, fountain surfaces or other water

features at use dilution rates. This option was

implemented in the lagoons in 2012 with mixed

results. The dye provided a significant reduction in

aquatic weed and algae growth and the residents for

the most part were fond of the color. However the

lagoons have been dealing with a fecal coliform issue for decades with counts regularly going

above the desired threshold. When the lagoons were shut down and made into a closed system

for the dye program, the fecal coliform counts increased and stayed at a high level. Basically the

closed system was not allowing the dilution and flushing that the open system provided.

Therefore the City of Alameda and the Alameda West Lagoon Home Owners Association

(AWLHOA) have decided that going with an open system is in their best interest moving

forward.

Sediment Removal:

Dredging is usually not performed solely for

aquatic plant management but to restore water

bodies that have been filled in with sediments, have

excess nutrients, have inadequate hypolimnetic

zones, need deepening, or require removal of toxic

substances. However, water bodies that are very

shallow due to sedimentation typically do have excess plant and algae growth. The City of

Alameda and the Alameda West Lagoon Home Owners Association (AWLHOA) have been

developing a dredging plan over the last several years. This plan includes dredging the entire

lagoon system with the goal of removing a significant amount of sediment. The main issue


Alameda Lagoons

Page 43 of 44

holding this project up is the enormous costs, which are estimated to be around a few million

dollars. Not only is the actual dredging expensive but the disposal of the dredged material is

where the costs really start adding up. Even if this

project is completed in the near future it would not

insure a reduction in aquatic plant growth or algae

blooms.

Mechanical

Mechanical removal of aquatic weeds is not recommended in the Alameda Lagoons as the

dominate weed species in the lagoons is Widgeon Grass (Ruppia maritime L.) which is capable

of asexual reproduction which takes place when new stems grow from the plant’s root and

rhizome system. The aquatic weed harvesters while cutting would be uprooting and spreading

the plants roots and rhizomes throughout the lagoons,

thus creating the potential for several new Widgeon

Grass infestations. Mechanical harvesting is also

pretty expensive when you add up the mobilization

costs, machine maintenance, support equipment, labor,

and the costs of removing the harvested material from

the site to the landfill.

INTEGRATED AQUATIC VEGETATION CONTROL RECOMMENDATIONS:

The recommended control strategy includes establishment of treatment thresholds, monitoring

protocols to determine when thresholds are exceeded, and protocols to implement control

measures when thresholds are exceeded in compliance with Best Management Practices. The

control recommendations to deal with exotic and nuisance aquatic vegetation growth present

within the systems have been determined based on survey results, and recommended schedules


Alameda Lagoons

Page 44 of 44

for aquatic vegetation control are outlined in the APAP. It is recommended that an integrated

approach that includes both watershed management and aquatic herbicide and algaecide

treatments be initiated to control nuisance growths of algae and aquatic vegetation prior to their

impact to the beneficial uses of the system.

A matrix that presents the control methods that have been reviewed for implementation follows:

Matrix of Control Options

OPTION METHOD PRACTICAL RANK

Watershed

Management

Structural

Non Structural

Implemented

Implemented

10

10

Biological Control Beneficial Bacteria and

Enzymes

Implemented 5

Physical and Cultural

Control

Sediment Removal

Light Limitation

Aeration

Draw Down

Hand Harvesting

Benthic Barriers

Planned

Being Tested

Not Practical

Not Practical

Not Practical

Not Practical

4

4

2

1

1

1

Mechanical Control Diver Dredging

Harvesting

Not Practical

Not Practical

1

1

Herbicides/ Algaecides Various Implemented 8

APAP UPDATES: This APAP will be updated as the General Permit conditions change, any

new algaecides or aquatic herbicides are need for the aquatic vegetation management program,

or as new control technologies are developed and become available.

END OF APAP

References

Water Quality Order No. 2013-0002-DWQ, General Permit No. CAG990005, Statewide

General National Pollutant Discharge Elimination System Permit for Residual Aquatic

Pesticide Discharges to Waters of the United States from Algae and Aquatic Weed

Control Applications.